Juror Bias Requires Court Inquiry

Roberts v. Florida, 36 Fla. L. Weekly D1651 (Fla. 4th DCA, Aug 3 2011): Defense Appeal, Reversed for New Trial – During deliberations a jury sent note to judge stating that she felt case was “too close to home.” Judge did not respond. “When suggestion of juror bias is not frivolous, the court should make ‘an adequate inquiry’ into whether the bias existed and whether it was prejudicial. (internal citation omitted)”